Broadcasters of all sizes will soon face a new layer of ownership scrutiny following the adoption of updated foreign sponsorship disclosure rules. The FCC order requires all commercial and non-commercial license holders to strictly certify whether any “foreign adversary” holds an attributable interest in their station.
The regulation defines a reportable interest as anything exceeding a 5 percent equity stake held by a government, entity, or citizen from a nation designated as a foreign adversary. While this rule is partially aimed at large media conglomerates, it has significant implications for small market owners who lease time to third-party programmers.
Under the new framework, licensees must vet their lessees to ensure that brokered programming is not funded or controlled by these designated foreign entities. This places the burden of due diligence squarely on the local license holder. Legal experts advise that station owners immediately update their lease agreements to include mandatory disclosure clauses from all program suppliers, as the FCC has indicated it will enforce strict liability for airing undisclosed foreign government propaganda.